Establishment of FTZs Foreign-Trade Zones are established: To encourage and expedite U.S. participation in international trade To expedite exportation of domestic goods with foreign and domestic content To defer payment of duties until goods enter into the commerce of the U.S.
Is FTZ 106 Right for You? IF YOU ANSWER “YES” TO ANY OF THE FOLLOWING THEN FTZ 106 CAN HELP. Do you manufacture, assemble or process with imports? Do you regularly pay more than $485 per week in merchandise processing fees? Do you scrap, reject, destroy, waste, or return some of your imports? Do you export previously imported materials?
Is FTZ 106 Right for You? IF YOU ANSWER “YES” TO ANY OF THE FOLLOWING THEN FTZ 106 CAN HELP. Do you have to wait long periods of time for your orders to get through border customs? Do you sell your imported products to companies that reside in Foreign Trade Zones? Are you selling to the military? Are you currently utilizing a Customs tariff- reduction program?
OK FTZ Regions (by counties) Oklahoma CUSTOMS PORTS OF ENTRY Oklahoma City42 You can take advantage of multiple sites, including importing directly into your physical location! 106
What is an FTZ? Usually located in or near Customs Ports of Entry at industrial parks or terminal warehouse facilities A FTZ site or park is a specially designated and secured area operating under U.S. Customs supervision Almost any type of goods may be brought in duty free for any kind of manipulation.
What is a FTZ? Foreign-Trade Zones are areas which are geographically inside the U.S. but are legally considered outside its Customs territory. Imports to the Zone FTZ 106 Exports Imports Admissions into FTZ: Duty Free Exports from FTZ: Duty Free Imports to U.S. from FTZ: Dutiable OKC
Types of Foreign Trade Zones How you can take advantage of FTZ 106 Become a General Purpose Operator Manufacturing Distributing Use a General Purpose Warehouse Become a Manufacturing Subzone A special purpose zone used for a limited purpose that cannot be accommodated in an existing zone. Normally privately owned.
What can you do in an FTZ? A facility where goods may be: receivedstored manipulatedmanufactured exhibitedexamined testedcalibrated destroyedexported repackedassembled mixed with domestic goods title transferred
FTZ Savings Derived exclusively from a tax management approach to U.S. Customs Duties and Fees. Realized in Four Ways: Customs Duty Elimination - Scrapping, Exports Customs Duty Reduction - Inverted Tariffs Deferral of Customs Duty Payment – Inventory (a one time benefit usually the least profitable of the 3) Customs Fee Reductions – Merchandise Processing Fees (MPF)
Duty Elimination Receiving Process Inbound Goods Quality Control Scrapped – Duty Free May be blanket or single transaction
Duty Elimination Assembled New Product B Exported Duty Free Imported Product A Potentially Dutiable EXPORT Import Duty Free
Inverted Duty Rate Component A 10% Duty Component B 12% Duty Component C 5% Duty Component B 5% Duty Component C 8% Duty Component A 5% Duty
Merchandise Process Fees 15 shipments/week MPF $7275 Shipments into commerce 15 shipments/week 1 entry filed at end of week. MPF $485 Shipments into commerce with weekly entry
Deferred Duty Product A Duty OwedProduct A Duty Paid
One-Time Benefit & Duty Deferral Explanation IMS Worldwide, Inc. Uncleared Merchandise Cleared Merchandise Distribution Center/Warehouse Duty paid on merchandise at time of clearance at Customs port of entry BEFORE FTZ OPERATIONS Shipping
One-Time Benefit & Duty Deferral Explanation IMS Worldwide, Inc. Uncleared Merchandise Cleared Merchandise Distribution Center/Warehouse Foreign merchandise admitted into FTZ; no duties paid at Customs port of entry. Shipping duty- paid merchandise using FIFO inventory record-keeping; no duties paid at point of shipment either. Formerly duty-paid merchandise being shipped from facility DURING FIRST INVENTORY TURN OF ACTIVE FTZ OPERATIONS
One-Time Benefit & Duty Deferral Explanation IMS Worldwide, Inc. Uncleared Merchandise Cleared Merchandise Distribution Center/Warehouse Distribution center full of uncleared merchandise now. Customs entry now made on merchandise which was admitted into the Zone. Duty paid at this point. AFTER FIRST INVENTORY TURN
Production Equipment May be admitted without payment of duties until completely assembled, installed, tested and used in full scale production. Merchandise shall be subject to classification according to its character, condition, and quantity at the rate of duty applicable at the time the equipment is used in production.
Other Benefits Lower administrative costs Lower security and insurance costs No time constraints on storage Shorter transit time – direct delivery Improved inventory control Informed customs officer
Public Benefits Help facilitate and expedite international trade. Allows you to continue to employ YOUR workers Help create employment opportunities
Who Supervises? U.S. Customs is responsible for ensuring compliance with the following regulations. 19 U.S.C. 81 a-81u 15 CFR PART 400 19 CFR PART 146
FTZ 106 Organization Approved industrial parks U.S. Dept. of Commerce U.S. Dept. of Treasury & Homeland Security U.S. Foreign-Trade Zones Board GRANTEE FTZ 106 PORT AUTHORITY OF GREATER OKC AREA Administrator General Purpose Operation on Site Biagi Brothers Warehouse Subzone Operator: ImationSubzone Operator: Xerox YOU!
Role of CBP Principle Interests and Concerns Control of merchandise moving to/from a zone Collection of all revenue Ensure adherence to laws and regulations Ensure merchandise has not been overtly or clandestinely removed from zone without proper Customs permit Ensure proper security measures at zone facilities
Role of Port Director Oversees the zone as the Board representative Reviews port policy and comments on applications Reviews and comments on various zone procedures Approves discretionary requirements (specific authority requests)
Role of Port Director Requires an adequate FTZ Operator’s Bond Assesses penalties and liquidated damages Initiates suspension, if necessary Recommends revocation to FTZ Board, if necessary
Terminology U.S. Foreign-Trade Zones Board Agency responsible for the establishment and administration of Zones through Board’s regulations Does not handle day-to-day administration of any Zones Provides grants to Grantees
Terminology Grantees Almost always public corporations or government agencies Establish, operate, and maintain Zones Enters into agreements with Operators or Subzones
Terminology Administrator Maybe subcontracted by the grantee for the purpose of overseeing or marketing the zone Luther Trent - Administrator 106 May be a source of technical expertise on Customs and FTZB issues
Terminology Operator or Subzones Responsible for compliance with Customs regulations relating to Zones Responsible for day-to-day operation of the Zone which can include warehousing, storage, transportation, distribution, and manufacturing May enter into agreements with Users
Terminology Users Uses a Zone for its benefits and pays the Grantee or Operator for their services such as rent on facilities, storage, handling, or manufacturing.
Fees Application fee - $5,000 to FTZ #106 Application fee - $4000 to Dept. of Commerce One time activation fee - $5,500 (upon approval of the application) Yearly administration of the operating agreement: Subzone or Manufacturing Zone Operator - $12,000 Private General Purpose Zone Operator - $6,000 Publicly Owned General Purpose Zone Operator - $4,000 Custom’s Warehouse Bonding fee - variable
Bonded Warehouse FTZ operators are required by Customs to be bonded. The amount required is variable based on the average value of single shipments. Shipment ValueBond Fee $100,000$500 $50,000$250 $10,000$100
Required Documents Admission, Removal, Activities, and Required Documents Only 4 Customs Forms (CBP) are required for normal operations: CBP 214: Application for FTZ Admission CBP 216: FTZ Activity Permit CBP 3461: Entry/Immediate Delivery CBP 7501: Entry (MPF)
Inventory Control and Record Keeping An Operator’s or User’s inventory tracking system (ITS) must account for: All merchandise in the Zone All merchandise removed from the Zone Location of merchandise Zone status Beginning balance, receipts, removals and current balance Destruction, scrap, waste, by-products Cost or value, unless, Operator financial records are available for Customs review
Inventory Control and Record Keeping Customs accepts any inventory tracking system that “protects the Revenue of the U.S.” First-In-First-Out Foreign-In-First-Out Lot specific Part number Bill of materials Liquid bulk FIFO Serial number specific Others
Confidentiality U.S. Customs is under specific legal restrictions against divulging: company cost quantity specification data on imported products No more or less subject to currently gathered and publicly reported trade statistics normal public entities
Confidentiality Any applications filed with the FTZ Board become public information, however, procedures exist in the regulations to protect sensitive and proprietary information. This protection supersedes the Freedom of Information Act
FTZ Cost/Benefit Analysis Benefits – What you save Duty Rate Reduction (Inverted Duty)$ 400,000 (EST) Merchandise Processing Fee Avoidance.21% of value vs. $485/wk max.$ 18,000 Deferred Duty Payment @ 7.5%$ 19,000 ____________________________________Total___$ 437,000 COSTS Brokers Fees Zone Operation vs. Standard Clearance Process$ 0 Operating Costs Change$ 0 Security Administration$ 10,000 Data Processing$ 5,000 Duty Payments on Unexpected “Up Adjustments”$ 5,000 U.S. Customs Assurance Bond$ 1,000 ____________________________________Total___$ 21,000 Net Benefit$416,000
Required Signage TARIFF ADMINISTRATION WARNING YOU ARE ENTERING A U.S. FOREIGN TRADE ZONE ALL PERSONS AND PACKAGES ENTERING OR LEAVING THE ZONE ARE SUBJECT TO INSPECTION WHOEVER MALICIOUSLY ENTERS WITH INTENT TO REMOVE THEREFROM ANY MERCHANDISE, OR UNLAWFULLY REMOVES MERCHANDISE FROM U.S. CUSTOMS SERVICE CUSTODY OR CONTROL SHALL BE GUILTY OF A FEDERAL CRIME AND FINE NOT MORE THAN $5000.00 OR IMPRISONED NOT MORE THAN 2 YEARS, OR BOTH (18 USC 549)
SMSB Fast Track T/IM Temporary/Interim Manufacturing Authority 500 employees or less. Will approve up to 5 products. Will approve up to 20 components and 10 inverted tariffs Standardized application 2 years temporary permit - permanent one at the end of the period. No additional application is necessary. Will be processed in 75 days.
Questions? For additional information call 405.680.3260